Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
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ITAT adjudicated a jurisdictional challenge regarding faceless assessment proceedings. The tribunal found the National Faceless Assessment Centre (NFeAC) lacked legal authority to issue notices under Section 142(1) prior to 29.03.2022. The e-assessment of income escaping assessment scheme, 2022 was notified on 29.03.2022, rendering prior proceedings invalid. Relying on precedent from a similar case, the tribunal determined that the NFeAC had no jurisdiction to conduct assessment or issue notices before the official notification date. Consequently, the tribunal allowed the assessee's appeal, effectively invalidating the assessment proceedings initiated before the statutory notification date.
ITAT adjudicated a jurisdictional challenge regarding faceless assessment proceedings. The tribunal found the National Faceless Assessment Centre (NFeAC) lacked legal authority to issue notices under Section 142(1) prior to 29.03.2022. The e-assessment of income escaping assessment scheme, 2022 was notified on 29.03.2022, rendering prior proceedings invalid. Relying on precedent from a similar case, the tribunal determined that the NFeAC had no jurisdiction to conduct assessment or issue notices before the official notification date. Consequently, the tribunal allowed the assessee's appeal, effectively invalidating the assessment proceedings initiated before the statutory notification date.
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